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Written Evidence Submitted by Pennon/South West Water Pennon Group

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Written Evidence Submitted by Pennon/South West Water Pennon Group Pennon /South West Water WQR0056 Written evidence submitted by Pennon/South West Water Pennon Group Pennon Group is a FTSE100 company and the owners of South West Water and Bournemouth Water. We provide water and wastewater services to a population of c.1.7 million in Cornwall, Devon and parts of Dorset and Somerset, and water-only services to c.0.5 million in parts of Dorset, Hampshire, and Wiltshire. South West Water sustains 6,000 jobs in the regional economy and, since 1989, has invested more than £7 billion to maintain and improve water and wastewater services. At the time of privatisation our coastal bathing waters were blighted by raw sewage outfalls but years of sustained investment by South West Water has transformed them into some of the best in Europe. Our pioneering Upstream Thinking catchment management scheme was one of the first to demonstrate nature-based improvements to water quality. We care deeply about the environment and are currently making our largest environmental investment for 15 years, with additional proposals submitted to Defra and our regulators to accelerate and expand investment to support a Green Recovery. In addition to the written views provided below, our CEO Susan Davy would be delighted to assist the Committee’s inquiry further by providing oral evidence. Summary of our view Our customers and communities are placing increasing importance on river water quality for amenity, in addition to ecology We care deeply about the environment and the priorities of our customers and communities - the environment is now our top priority, second only to safe clean drinking water Experience has taught us that working in partnership and understanding how most effectively to intervene will be essential if we are to play our part in delivering a step-change in river quality. This requires pilot schemes to prove the case for investment and identify best practice, which we are proposing for the rivers Dart and Tavy To gain understanding and trust, there is a need for transparency and information sharing. We have submitted proposals to make significant investment in additional monitoring and are committed to making data publicly available in real-time Regulation is developing in the right way, towards an outcomes-based approach that encourages all sectors to play their part – but now needs to reflect natural and social capital base lines that can assist in measuring and targeting further improvements not least through partnership working. Catchment and systems level approaches require multiple sectors and drainage bodies to all play their part. How adequate are the monitoring and reporting requirements around water company discharges? How can technology improve and assist with transparency and enforcement? Improving river quality will require long-term investment and for water companies to work in partnership with other organisations. Increased transparency and information sharing will underpin efforts to build trust and understanding. Good quality data will allow informed choices to be made. Currently, monitoring of continuous treated discharges from Wastewater Treatment Works is well advanced and understood. For storm overflows, South West Water has Event and Duration Monitors (EDM) on over 70% of our storm overflows and Green Recovery proposals to monitor all storm overflows by 2023. However, data on how often a storm overflow operates is not on its own an effective measure of environmental impact. The new Storm Overflow Assessment Framework (SOAF), is a good step forward to address this. The SOAF process is a trigger to investigate the storm overflows which operate frequently and looks at the root cause, environmental conditions and the economic case to improve – this is shared Pennon /South West Water WQR0056 with the Environment Agency to create new investment drivers where supported. The economic test is important since it ensures that society will benefit from any investments and associated improvements. Identifying the sources and impacts of pollution is critical if we are to introduce effective new targets and improve river quality. Source apportionment and environmental monitoring by the Environment Agency are key to understanding the baseline environmental conditions and where action needs to be taken so these activities should be least maintained and preferably expanded. In terms of technology, whilst storm discharge operations can be measured in terms of duration, it is much more difficult to measure the volume and load – these are vital considerations in determining where improvements in performance will deliver worthwhile environmental benefits, and technology to do this simply and at scale should be explored. This would also assist with the transparency need and making the best societal decisions. What are the best indicators for river water quality that could be used as targets being developed under the Environment Bill? For amenity, bacteria would be the key indicator for river quality. Meeting a target on bacteria would require identifying and addressing its source, which our decade-long experience of catchment management tells us would be best met through working in partnership with agriculture, landowners, and environmental charities. The UK has river water quality standards under the Water Framework Directive. For coastal waters bacteria is the lead indicator of bathing water quality – this is a health rather than an environmental standard. However, in rivers bacteria have no environmental consequence so would only be a potential problem if present at the same time as water users. Rivers are markedly different to coastal waters in that once a storm overflow or catchment input has ceased then the bacteriological water quality at that point will improve very quickly due to the linear flow – so timing of impacts from all sources and timing of use are key considerations. Consequently, it is doubtful that the Bathing Water Directive would be the right tool to address amenity river water quality standards. How to improve bacteriological river quality is further complicated by the fact there are no regulatory standards and no baseline sampling or source apportionment, unlike for coastal bathing waters. In the event of storms river water use is likely to be low/none, although some water users such as canoeists may seek out the higher-flowing water present after storm events. So, the exact location of river use and the type of use is important in understanding what targets and measures are most appropriate, and indeed if any are needed. We believe the best way to understand what is required to facilitate amenity river use is through trials. However, a cross-sectoral national group should also be established with the regulators to consider how best to identify, set and monitor non-environmental indicators. There is an imperative to improve all aspects of river water quality. In our region, agriculture is the source of twice the number of issues preventing waters reaching ‘good status’ as wastewater. South West Water’s pioneering Upstream Thinking scheme uses multi-benefit nature-based solutions to improve water quality upstream of our abstraction points. Our schemes also restore habitats, reduce carbon emissions and form long-term partnerships with farmers and/or landowners, the Wildlife Trusts, and South West Water, to identify sources of pollution in catchments and prevent them entering watercourses. The solutions reduce a range of contaminants entering watercourses, including; farming-derived nutrients, pesticides, faecal coliforms, sediment, dissolved organic carbon (DOC) and new emerging issues such as veterinary medicines and antibiotics. Through almost a decade of experience, we have found that a combined approach of restoring habits and working with farmers/landowners can have a sustained positive impact on river water quality. Actions to address sources of agricultural pollution are often relatively small, such as advice from specialists or grants for new concrete yards or barns but need to be taken at multiple points across a catchment. Pennon /South West Water WQR0056 Our Upstream Thinking approach works where there is a mutual benefit for our customers in that drinking water quality issues can be addressed in the most cost-effective way through catchment interventions. However, Upstream Thinking is not scalable, as a customer-funded vehicle, to catchments where we do not have direct cost-effective benefits for customers to be realised. We have been advocating that the Environmental Land Management system (ELMS) will be key to addressing agriculture-led catchment improvements for wider river water quality, be that for environment or amenity benefits. How could drainage and sewage management plans, introduced by the Environment Bill, play a role in reduced sewer discharges? Whilst water companies are often at the end of complex drainage systems, there are multiple upstream responsibilities that are frequently not being met, including private drainage problems, highways drainage problems and rural run-off and riverine flooding and inundation of our systems. Partnerships are key to resolving these issues and we are developing Drainage and Wastewater Management Plans for our whole region to better enable joined-up solutions. These plans will be successful only if co-deliverers and co- funders from the other responsible drainage authorities step-up and play their part in catchment level solutions to complex and sometimes longstanding problems. How could the designation of inland
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